RECORD OF DECISION · Estimated capital, operating and maintenance (O&M), and total net present worth (NPW) costs; discount rate; and number of years over which the remedy costs are

RECORD OF DECISION

Operable Unit 27 ‐ Site 41

Former Pesticide Storage Building 1485C Surface and Subsurface Soil

Naval Air Station Whiting Field Milton, Florida

USEPA ID No. FL2170023244

March 2011

NAS Whiting Field Site 41 ROD

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1.0 DECLARATION

1.1 SITE NAME AND LOCATION

Operable Unit (OU) 27 – Site 41, Former Pesticide Storage Area Building 1485C, at Naval Air Station (NAS) Whiting Field, Milton, Florida, United States Environmental Protection Agency (USEPA) ID number FL2170023244. The site location is presented in Figure 1-1. 1.2 STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the Selected Remedy for surface and subsurface soil at OU 27 - Site 41, Former Pesticide Storage Area Building 1485C, which was chosen by the Navy and USEPA in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on information contained in the Administrative Record for the site. The Florida Department of Environmental Protection (FDEP) concurs with the Selected Remedy. 1.3 ASSESSMENT OF SITE

The response action selected in this ROD is necessary to protect the public health and welfare or the environment from releases of hazardous substances into the environment. A remedial action is required because concentrations of carcinogenic polynuclear aromatic hydrocarbons (cPAHs) and dieldrin in soil pose unacceptable risk to human health under current and future land use scenarios. 1.4 DESCRIPTION OF SELECTED REMEDY

The major components of the Selected Remedy for Site 41 include: Excavation and off-site disposal of soil with concentrations of cPAHs and dieldrin greater than FDEP

direct exposure commercial/industrial Soil Cleanup Target Levels (SCTLs). Implementation of land use controls (LUCs) to ensure that future use of the property is limited to non-

residential activities and to prohibit excavation and uncontrolled removal of soil from the site. The Selected Remedy will eliminate unacceptable risks by precluding exposure to soil with contaminant of concern (COC) concentrations greater than FDEP commercial/industrial SCTLs (FDEP, 2005) and by implementing LUCs to limit future site uses to non-residential activities and to preclude disturbance of the soils without prior authorization. The remediation of Site 41 will not adversely impact the current and reasonably anticipated future land use of the site as a storage and equipment lay-down area. The Selected Remedy is expected to achieve substantial long-term risk reduction and allow the property to be used for the reasonably anticipated future land use, which is industrial. This ROD documents the final remedial action for Site 41 soil and does not include or affect any other sites at the facility. Groundwater at NAS Whiting Field is being addressed separately as Site 40 and will be addressed in a future decision document. There is no surface water or sediment associated with Site 41. Environmental work at Site 41 is part of the Navy’s ongoing Installation Restoration (IR) Program, which includes 27 OUs at NAS Whiting Field. The IR Program is a Department of Defense program to investigate and, if necessary, cleanup conditions related to suspected past releases of hazardous materials at military facilities. Currently, 24 of the 27 OUs at NAS Whiting Field have final RODs documenting remedy selection, and remedy implementation at those OUs has either been completed or is ongoing. Implementation of the remedy at Site 41 will remove low threat source material and return the site to its reasonably anticipated land use allowing industrial/commercial reuse of the site, which is consistent with current use and the overall cleanup strategy for NAS Whiting Field of restoring sites to support base operations.


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Figure 1-1 Site 41 Location Map


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1.5 STATUTORY DETERMINATIONS

The Selected Remedy is protective of human health and the environment, complies with federal and state requirements that are applicable or relevant and appropriate to the remedial action, is cost-effective, and utilizes permanent solutions and alternative treatment (or resource recovery) technologies to the maximum extent practicable. The Selected Remedy does not satisfy the statutory preference for remedies that use treatment as a principal element to reduce the toxicity, mobility, or volume of hazardous substances, pollutants, and contaminants. The type and relatively low concentrations of soil contamination make treatment impracticable. In addition, no source materials constituting principal threats will be addressed within the scope of this action. USEPA generally expects to use containment rather than treatment to address contamination such as that at Site 41, which poses a relatively low long-term threat to human health and the environment. Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on site in excess of levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within 5 years of initiation of the remedial action and every 5 years thereafter to ensure that the remedy is, or will be, protective of human health and the environment. In addition, annual LUC compliance inspections will be conducted. 1.6 ROD DATA CERTIFICATION CHECKLIST

The locations in Section 2.0, Decision Summary, of the information required to be included in the ROD are summarized in Table 1-1. Additional information can be found in the Administrative Record file for NAS Whiting Field.

TABLE 1-1. ROD DATA CERTIFICATION CHECKLIST DATA LOCATION IN ROD

Contaminants of concern (COCs) and their respective concentrations Sections 2.5 and 2.7

Baseline risk represented by the COCs Section 2.7

Cleanup levels established for COCs and the basis for these levels Section 2.7 and 2.8

How source materials constituting principal threats are addressed Section 2.11

Current and reasonably anticipated future land use assumptions and current and potential future beneficial uses of groundwater used in the risk assessment

Section 2.6

Potential land and groundwater uses that will be available at the site as a result of the Selected Remedy

Section 2.12.3

Estimated capital, operating and maintenance (O&M), and total net present worth (NPW) costs; discount rate; and number of years over which the remedy costs are projected

Appendix B

Key factors that led to the selection of the remedy Section 2.12.1

If contamination posing an unacceptable risk to human health or the environment is discovered after execution of this ROD and is shown to be a result of Navy activities, the Navy will undertake the necessary actions to ensure continued protection of human health and the environment.


o 1.7 AUTHORIZING SIGNATURES

Matt Coughlin Date Captain, United States Navy Commanding Officer NAS Whiting Field, FL

ranklin E. Hill, Director Superfund Division

Date

USEPA Region 4

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2.0 DECISION SUMMARY

2.1 SITE NAME, LOCATION, AND BRIEF DESCRIPTION

NAS Whiting Field, USEPA ID number FL2170023244, is located in Santa Rosa County, in Florida's northwestern coastal area, approximately 5.5 miles north of Milton and 25 miles northeast of Pensacola. The installation was constructed in the early 1940s and since has served as a Naval aviation training facility. NAS Whiting Field is approximately 3,842 acres in size and presently consists of two airfields (North and South Fields) separated by an industrial area. Current land use at NAS Whiting Field consists of various military housing, training, and support facilities for flight and academic training. OU 27 - Site 41, Former Pesticide Storage Building 1485C, occupies approximately 23,000 square feet in the central industrial area of NAS Whiting Field (see Figure 2-1). Former Building 1485C was located within the Base Operating Services Compound northwest of the eastern termination of Yorktown Street and was used during an undetermined period of time for storage of ground maintenance equipment and limited amounts of pesticide compounds. The site has been in use since the early 1960s. The storage building caught fire in the late 1980s and was completely destroyed. Following the fire, cleanup activities at the site included the removal of all building materials, the concrete slab flooring, and an unknown quantity of soil. The depth of the removal and the disposal history of the excavated materials are unknown. Site 41 was initially designated Potential Source of Contamination (PSC) 1485C; therefore, many of the initial sample numbers and references reflect the original site nomenclature. The site is currently surrounded by several buildings, enclosed by a chain-link fence, and covered mostly by grass. NAS Whiting Field is an active facility, and environmental investigations and remediation at the base are funded under Environmental Restoration, Navy (ER,N). The Navy is the lead agency for CERCLA activities at the facility, and USEPA and FDEP are support agencies. 2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES

Table 2-1 provides brief summaries of previous investigations conducted at Site 41. Results of these investigations indicated elevated concentrations of cPAHs, pesticides, and inorganics in soil at the site (Tetra Tech, 2010). There have been no cited violations under federal or state environmental law or past enforcement actions pertaining to the cleanup of Site 41.

2.3 COMMUNITY PARTICIPATION

The Navy performs public participation activities in accordance with CERCLA and the NCP throughout the site cleanup process at NAS Whiting Field. The Navy has a comprehensive community relations program for NAS Whiting Field, and community relations activities are conducted in accordance with the NAS Whiting Field Community Relations Plan. These activities include regular technical and Restoration Advisory Board (RAB) meetings with local citizens and the establishment of an Information Repository at the local library for dissemination of information to the community.

The Navy organized a RAB in 1995 to review and discuss NAS Whiting Field environmental issues with local community officials and concerned citizens. The RAB consists of representatives of the Navy, USEPA, FDEP, and members of the community. The RAB has met frequently (usually once a year) since its inception. Site 41 investigation activities, results, and associated remedial decisions have been discussed at RAB meetings. The NAS Whiting Field Information Repository is located at the Santa Rosa County Library, Milton Branch, 5541 Alabama Street, Milton, Florida, 32570. Documents and other relevant information relied upon in the remedy selection process are available for public review in the Information Repository, which includes a copy of the Administrative Record. For additional information on the IR Program at NAS Whiting Field, contact: Mike Pattison, NAS Whiting Field, Public Works Department, 7183 Langley Street, Milton, Florida 32570-6159, (850) 623-7017or e-mail at [email protected].


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FIGURE 2-1 SITE 41 SITE LAYOUT


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TABLE 2-1. PREVIOUS INVESTIGATIONS AND SITE DOCUMENTATION INVESTIGATION DATE ACTIVITIES

Navy Risk Ranking 1996 In March 1996, Brown & Root Environmental Services, Inc., collected a single surface soil sample (0 to 1 feet deep) at the site to support the Navy’s relative risk ranking. The soil sample was analyzed for Target Compound List (TCL) volatile organic compounds (VOCs), TCL semivolatile organic compounds (SVOCs), TCL pesticides/polychlorinated biphenyls (PCBs), and Target Analyte List (TAL) metals. No organic compounds or inorganic analytes were detected in excess of regulatory limits.

Initial Remedial Investigation (RI)

2000 Four direct-push technology (DPT) borings were advanced to a depth of 20 feet below land surface (bls) on April 13, 2000, at locations projected to be near the boundaries of the former structure. Subsurface samples were collected from each boring at 5-foot intervals and screened on site with a flame ionization detector (FID). These subsurface soil samples did not exhibit a significantly elevated FID response, staining, or other indications that would warrant laboratory analysis. On May 24, 2000, six surface soil samples (0 to 1 foot bls) were collected near the originally indicated boundaries of the former structure. Sample locations were co-located with the DPT sample locations of April 13, 2000. These samples were analyzed using the Synthetic Precipitate Leaching Procedure (SPLP) for metals, pesticides, SVOCs (samples SS02, SS03, and SS06 only), and total recoverable petroleum hydrocarbons (TRPH).

Additional RI Sampling

2001 Only benzo(a)pyrene [B(a)P] and pesticides were detected in initial soil samples; therefore, analysis was limited to B(a)P and pesticides for the next group of samples (collected in 2001). These analytes were used as indicators of soil contamination at the site. Eight surface soil samples (0 to 1 foot bls) were collected on May 17, 2001, near where SVOCs or pesticides were detected previously. Based on additional information from on-site workers, the sampling area was extended approximately 20 feet to the south-southwest. On August 15, 2001, surface soil samples (0 to 1 foot bls) were collected from locations to further evaluate this additional area. Three surface soil samples were collected and analyzed for SVOCs and pesticides.

Further RI Sampling

2003/ 2004

Additional surface and subsurface soil samples were collected on October 16, 2003. B(a)P was used as an indicator chemical, and samples were analyzed for this compound only. Thirteen surface soil samples and 16 subsurface soil samples were collected during this sampling event. On November 10 and 11, 2003 Tetra Tech conducted sampling at 14 soil borings at locations south, east, and north of the former structure. Soil boring locations sampled during this event included SB34 through SB47. Three soil samples (from 0 to 1 foot bls, 1 to 2 feet bls, and 2 to 3 feet bls) were collected from each of these locations. All samples were analyzed for TCL, VOCs, SVOCs, pesticides/PCBs, TRPH, TAL inorganics, and cyanide. On August 31, 2004, additional samples were collected from 19 soil borings to the east, west, and north of the former structure. Sampling locations were selected to further delineate the horizontal and vertical extent of SVOC and/or pesticide soil contamination detected during previous sampling events. All samples collected during this event were analyzed for the SVOCs B(a)P and dibenzo(a,h)anthracene [D(a,h)A], and the pesticides aldrin, dieldrin, and heptachlor. Three subsurface soil samples were collected from each soil boring to depths of up to 6 feet bls. Also during this sampling event, soil samples were collected from each soil boring at locations SS48 through SS53. A surface soil and two subsurface soil samples were collected at each location and analyzed for the five compounds indicated above.

RI Report and Feasibility Study (FS)

2010 Based on the nature and extent of soil contamination determined during the RI, an FS was conducted to develop and evaluate soil remedial alternatives. Additional soil delineation will be required prior to implementation of the remedy.


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In accordance with Sections 113 and 117 of CERCLA, the Navy provided a public comment period from January 10 to February 9, 2011, for the proposed remedial action described in the Proposed Plan (Tetra Tech, 2011b) for Site 41. Public notice of the meeting and availability of documents were published in the Pensacola News Journal and Santa Rosa Press Gazette on January 9 and 10, 2011, respectively.

2.4 SCOPE AND ROLE OF OPERABLE UNIT

Site 41 is part of a comprehensive environmental investigation and cleanup program currently being performed at NAS Whiting Field under CERCLA authority pursuant to the Federal Facility Agreement (FFA) dated March 9, 2009 (effective July 10, 2009). IR Program cleanup activities are being performed under CERCLA, except at those sites subject to the FDEP Underground Storage Tank (UST) Program. As discussed in Section 1.4, 27 IR sites have been identified at NAS Whiting Field. USEPA, Navy, and FDEP staff-level project managers agreed that no further investigation, i.e., no RI/FS, was warranted for three sites including Sites 8, 36, and 37. Sites 4 and 7 were deferred to the FDEP UST Program. A No Further Action ROD for soil at Site 31 was signed in September 2002, for soil at Sites 3 and 6 in September 2004, for soil at Sites 5, 9, 12, 29, and 38 in September 2005, for soil at Site 14 in September 2006, and for soil at Site 2 in October 2008. RODs implementing LUCs as the remedial action were signed for soil at Site 1 in September 1999, Sites 30, 32, and 33 in September 2004, Sites 13, 17, 18, and 35 in September 2006, Sites 10 and 11 in September 2007, and Site 16 in October 2008. The Site Management Plan (SMP) for NAS Whiting Field further details the schedule for CERCLA activities and is updated annually.

2.5 SITE CHARACTERISTICS

Figure 2-2 presents the Site 41 conceptual site model (CSM), which identifies potential contaminant sources, contaminant release mechanisms, transport routes, and receptors under current and future land use scenarios. The source of contamination at Site 41 is likely related to pesticide and equipment storage, and potential contaminant release and transport mechanisms include precipitation infiltration and migration to subsurface soil and runoff and erosion of contaminated soil via wind and/or stormwater runoff. Because the site surface is relatively level and mostly covered with grass, erosion via wind and runoff are considered minimal. Human health and ecological receptors are discussed in Section 2.7.1 and 2.7.2, respectively.

2.5.1 Physical Characteristics

The surface of Site 41 is relatively level and is predominantly covered by grass, with some gravel at the southern edge. The soils at Site 41 include three lithologic layers to a depth of 20 feet bls. The first layer (0 to 7 feet bls) is a clayey sand, the second layer (7 to 15 feet bls) is a sandy clay, and the third layer (15 to 20 feet bls) is a clayey sand. The soil is characterized as Troupe loamy sand by the United States Department of Agriculture (USDA) classification system.

2.5.2 Nature and Extent and Fate and Transport of Contamination

The RI concluded that the release of contaminants at Site 41 appears to have resulted from storage and disposal of pesticides used for maintenance of the base grounds and other undocumented activities at the site. The source and nature of materials and the time of disposal are not precisely known in terms of timing, incident, or process. During the RI, several iterative sampling events were conducted from 2000 to 2004 during which a total of 53 surface soil and 67 subsurface soil samples were collected and analyzed for various parameters. Analytical results were compared to FDEP SCTLs (FDEP, 2005), NAS Whiting Field background screening values for inorganics only, and USEPA Regional SSLs (USEPA, 2008) to determine if contaminants in soil samples exceeded regulatory criteria.


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Constituents detected in surface and subsurface soil samples from Site 41 included PAHs, pesticides, inorganics, cyanide, and TRPH. The conclusions of the Site 41 RI were as follows: PAHs [benzo(a)anthracene, B(a)P, benzo(b)fluoranthene, D(a,h)A, fluoranthene, indeno(1,2,3-

cd)pyrene, phenanthrene, and pyrene] were detected in surface soil at Site 41 in several locations, including SB47, SS07, and SB41.

Large areas of pesticide [4,4-dichlorodiphenyldichlorethane (DDD), 4,4-dichlorodiphenyl-

dichloroethylene (DDE), 4,4-dichlorodiphenyltrichloroethane (DDT), and dieldrin] exceedances are present in surface soil in the southeastern and northwestern portions of Site 41.

Two areas of inorganic (chromium, lead, and zinc) exceedances were defined, south and southwest

of SB37 and also northwest, north, and northeast of SB43 and SB44. Lead was also detected in the SPLP leachate from surface soil samples SS01, SS04, SS05, and

SS06 at concentrations exceeding primary criteria.

SVOC exceedances at SB43 were delineated in all directions except to the south where the former building was located. A second area associated with locations SB31 and SB35 is well defined in all directions except southwest of SB35.

Pesticide (4,4-DDE and dieldrin) exceedances at SB37 have not been delineated to the south or

southwest. Exceedances associated with SB41 and SB43 have been laterally delineated.

FIGURE 2-2. CONCEPTUAL SITE MODEL


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Surface and subsurface soil exceedances of residential and industrial screening criteria are presented on Figure 2-3. Estimated volumes of contaminated soil generated during the FS for residential and industrial scenarios were 836 and 88 cubic yards, respectively (Tetra Tech, 2011a). Pesticides such as dieldrin have low mobility but are highly persistent contaminants that, when released to the environment, generally adsorb to the soil matrix and remain bound to particulate matter. PAHs are also considered to be persistent in the environment and are much more likely to bind to soil than to go into solution. PAHs are subject to degradation via aerobic bacteria but may be relatively persistent in the absence of microbial population or macronutrients such as phosphorus and nitrogen. Because of their persistence and tendency to adhere to soil particles, both PAHs and pesticides tend to migrate from source areas via bulk movement processes (e.g., surface runoff and wind erosion) and, if leaching from soil to groundwater occurs, it usually results in transportation over relatively short distances. 2.6 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES

NAS Whiting Field is an active military facility and is expected to remain active for the foreseeable future. Current land use at NAS Whiting Field consists of various aviation-related military training, housing, and support facilities and large industrial complexes for major repairs and refurbishment of aircraft. NAS Whiting Field provides the support facilities for flight and academic training. Other land uses on base include equipment and materials storage, maintenance areas, and recreational facilities for military personnel. Land surrounding NAS Whiting Field consists primarily of agricultural land to the northwest, residential and forested areas to the south and southwest, and forested areas along the remaining boundaries. Elevations at NAS Whiting Field, located on an upland area, range from 50 to 190 feet above sea level. The facility is bounded by the following low-lying receiving waters: Clear Creek to the west and south and Big ColdwaterCreek to the east. These two streams are tributaries of the Blackwater River, which discharges to the estuarine waters of the East Bay of the Escambia Bay coastal system. Both Clear Creek and Big Coldwater Creek are classified by the FDEP as Class III Waters Recreation-Propagation and Management of Fish and Wildlife. Blackwater River is classified as an Outstanding Florida Water. Outstanding Waters are considered to be of exceptional recreational and ecological significance. On-site wildlife may temporarily use Site 41, but due to lack of suitable cover, wildlife habitat is limited and use is assumed to be infrequent. Industrial/commercial-type use of the site is expected to continue for the foreseeable future. The NAS Whiting Field Master Plan identifies the planned future use of the site as an industrial lay-down area, indicating that no future development or construction activities are planned for the site. If future land use at Site 41 differs from the reasonably anticipated land use, the Navy will reassess risks appropriate to the future use with input from USEPA and FDEP. Three potable water wells (North, West, and South wells) are located on NAS Whiting Field and provide the main source of potable water for the base. The water supply wells are completed at depths ranging from 230 to 263 feet bls and extract groundwater from the sand and gravel aquifer. The nearest potable water well (the North well) is located approximately 800 feet west-northwest of Site 41. No surface water bodies are located within or near the site boundaries. 2.7 SUMMARY OF SITE RISKS

The baseline risk assessment estimates what risks the site poses if no action was taken. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. A human health risk assessment (HHRA) and ecological risk assessment (ERA) were conducted as part of the Site 41 RI.

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2.7.1 Summary of Human Health Risk

The quantitative HHRA was conducted using chemical concentrations detected in surface and subsurface soil samples collected at Site 41 and using both USEPA and State of Florida regulations and guidelines for HHRA. Key steps in the risk assessment process included identification of contaminants of potential concern (COPCs), exposure assessment, toxicity assessment, and risk characterization. Tables summarizing data used in the HHRA and associated results are presented in Appendix C.

Identification of COPCs

Tables D-1 through D-10 from the Site 41 RI Report (included in Appendix C) present exposure point concentrations (EPCs) for the COPCs identified in surface and subsurface soil at Site 41. EPCs are the concentrations used in the risk assessment to estimate exposure and risk from each COC. Based on the statistical distributions of the data and the results of preliminary calculations, maximum detected concentrations or 95-percent upper confidence limits (UCLs) on the mean were used as the EPCs for Site 41 COPCs. COPCs were selected for quantitative evaluation based on comparisons of surface and subsurface soil concentrations to FDEP direct contact risk-based SCTLs. Constituents identified as potential threats to human health based on this initial screening (cPAHs, dieldrin, and chromium for surface soil and cPAHS, 4,4’-DDT, aldrin, and dieldrin for subsurface soil) were identified as COPCs and evaluated in the baseline risk assessment.

Exposure Assessment

During the exposure assessment using USEPA methodology (USEPA, 1988), current and potential future exposure pathways through which people might come into contact with the COPCs identified in the previous step were evaluated. The results of the exposure assessment for Site 41 were used to refine the CSM (Figure 2-2). Exposures to soil contamination via dermal contact (skin exposure), incidental ingestion (swallowing small amounts of soil), and inhalation (breathing) are the only current exposure pathways, and current receptors include site maintenance (e.g., groundskeeping) workers and adult and adolescent recreational users/trespassers. In addition to current receptors, potential future receptors include construction/excavation workers, occupational workers, and hypothetical child and adult residents. Potential soil exposure routes for these receptors also include incidental ingestion, dermal contact, and/or inhalation. The future residential scenario was quantitatively evaluated in the risk assessment for decision-making purposes, although this scenario is unlikely (i.e., is not the reasonably anticipated land use) at Site 41. Current and hypothetical future exposure pathways evaluated during the Site 41 risk assessment are summarized in Table 2-2.

Toxicity Assessment

The toxicity assessment involves identifying the types of adverse health effects caused by exposure to site COCs and determining the relationship between the magnitude of exposure and the severity of adverse effects (i.e., dose-response relationship) for each COPC. Based on the quantitative dose-response relationships determined, toxicity values for both cancer (cancer slope factor [CSF]) and non-cancer (reference dose [RfD]) effects are generally used to estimate the potential for adverse effects. The SCTLs presented in Tables D-1 through D-10 based in Appendix C are risk-based values derived to represent direct contact risks of 1 x 10-6 for carcinogens and hazard quotients (HQs) of 1.0 for non-carcinogens. Potential health effects are contaminant specific and may include an increased risk of developing cancer or non-cancer effects such as changes in normal functions of organs or organ systems. Some contaminants can cause both cancer and non-cancer effects. Toxicity data used to derive FDEP SCTLs indicate potential cancer risk associated with cPAHs and cancer risks and non-cancer hazards associated with 4,4-‘DDT, aldrin, dieldrin and chromium. The available toxicity data indicate that 4,4-‘DDT, aldrin, and dieldrin primarily affect the liver, and chromium primarily affects the respiratory system.


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TABLE 2-2. RECEPTORS AND EXPOSURE ROUTES EVALUATED IN HHRA RECEPTOR EXPOSURE ROUTES

Adult and Adolescent Trespassers/Recreational Users (current and future land use)

Soil dermal contact (surface soil) Soil ingestion (surface soil) Inhalation of air/dust/emissions (surface soil)

Maintenance Workers (current and future land use)

Soil dermal contact (surface soil) Soil ingestion (surface soil) Inhalation of air/dust/emissions (surface soil)

Construction Workers (future land use)

Soil dermal contact (surface and subsurface soil) Soil ingestion (surface and subsurface soil) Inhalation of air/dust/emissions (surface and subsurface soil)

Occupational Workers (future land use)

Soil dermal contact (surface soil)(1) Soil ingestion (surface soil)(1) Inhalation of air/dust/emissions (surface soil)(1)

Residents (Adults/Children) (hypothetical future land use)

Soil dermal contact (surface soil)(1) Soil ingestion (surface soil)(1) Inhalation of air/dust/emissions (surface soil)(1)

1 - Occupational workers and residents were also evaluated for exposure to COPCs in subsurface soil to account for the possibility that subsurface soil could be brought to the surface in future excavation projects

Risk Characterization

During the risk characterization, the outputs of the exposure and toxicity assessments are combined to characterize the baseline risk (cancer risks and non-cancer hazards) at the site if no action was taken to address the contamination. Potential cancer risks and non-cancer hazards are generally calculated based on reasonable maximum exposure (RME) and central tendency exposure (CTE) assumptions. The RME scenario assumes the maximum level of human exposure that could reasonably be expected to occur, and the CTE scenario assumes a median or average level of human exposure. For carcinogens, risks are generally expressed as the incremental probability of an individual developing cancer over a lifetime as a result of exposure to the carcinogen. These calculated risks are probabilities that are usually expressed in scientific notation (e.g., 1 x 10-6). An excess lifetime cancer risk of 1 x 10-6

under an RME scenario indicates that an individual experiencing the reasonable maximum exposure estimate has a 1 in 1 million chance of developing cancer as a result of site-related exposure. USEPA’s generally acceptable risk range for site-related exposures is 1 in 10,000 to 1 in 1 million (1 x 10-4 to 1 x 10-6) and FDEP has a target risk of 1 in 1 million (1 x 10-6). Risk characterization results for Site 41 are presented in Tables D-1 through D-10 in Appendix C. Cancer risks were estimated using a risk ratio approach by dividing EPCs by the risk-based SCTLs and multiplying by 1 x 10-6 because SCTLs for carcinogens are based on risks of 1 x 10-6. Risks to hypothetical future recreational users at Site 41 were evaluated using site-specific SCTLs developed in accordance with applicable guidelines. Total risk estimates for Site 41 ranged from 8.0 x 10-7 for adolescent recreational users exposed to surface soil to 1.0 x 10-5 for hypothetical future residents exposed to surface soil. These risk levels indicate that if no cleanup action was taken, the increased probabilities of developing cancer as a result of site-related exposure would range from approximately 1 in 100,000 to 8 in 10,000,000. The potential for non-carcinogenic effects is generally evaluated by comparing an exposure level over a specified time period (e.g., a lifetime) to an RfD derived for a similar exposure period. An RfD represents a level to which an individual may be exposed that is not expected to cause any deleterious effect. The


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ratio of exposure to toxicity is called an HQ. An HQ less than 1 indicates that a receptor’s dose of a single contaminant is less than the RfD and that toxic non-carcinogenic effects from that chemical are unlikely. For Site 41, non-cancer hazards were estimated by dividing EPCs by the risk-based SCTLs (based on HQs of 1.0). Estimated non-cancer hazards for all surface and subsurface COPCs were less than 1 (acceptable). Cancer risk estimates (incremental lifetime cancer risks [ILCRs]) developed for maintenance workers and adult and adolescent recreational users exposed to COPCs in surface soil and for construction workers exposed to COPCs in subsurface soil were less than 1 x 10-6. Total ILCRs for construction workers and lifelong recreational users exposed to surface soil and full-time commercial/industrial workers and hypothetical future residents exposed to surface and subsurface soil were within the USEPA target risk range of 1 x 10-4

to 1 x 10-6 but were greater than the FDEP target risk of 1 x 10-6. The primary risk drivers were cPAHs and dieldrin in surface soil and cPAHs, aldrin (residential scenario only), and dieldrin in subsurface soil. Non-cancer hazard estimates (HQs) for all receptors evaluated were less than unity (1.0). Consequently, adverse non-carcinogenic health effects are not anticipated under the conditions established in the exposure assessment.

2.7.2 Summary of Ecological Risk

A screening-level ERA, consisting of Steps 1 through 3A of the Navy’s ERA process, was conducted at Site 41. Complete exposure pathways and routes of entry into biota at Site 41 include direct contact with soil (soil invertebrates and terrestrial vegetation), ingestion of soil (soil invertebrates, birds, and small mammals), and ingestion of contaminated food items (birds and small mammals) (see Figure 2-2). Because the site is largely covered by vegetation, airborne transport of dust was considered a negligible pathway for terrestrial animals and aerial deposition was considered a negligible pathway for plants and animals. Ecological receptors are not directly exposed to contaminants in groundwater at the site, and surface water is not present at or near Site 41. Contaminant migration pathways applicable at this site include erosion and infiltration. Because the site is essentially covered with vegetation, wind erosion is not a significant migration pathway. However, if surface soil is disturbed through activities such as excavation, soils could serve as a source for airborne transport of contaminants, and soil contaminants could then be transported to downwind locations. Soil erosion due to storm water runoff is minimal at Site 41 due to the essentially level terrain and vegetative cover. No constituents were retained as COPCs for risk to plants, soil invertebrates, or wildlife at Site 41. Based on these results, the Navy and USEPA, in consultation the FDEP, determined no action to address ecological receptors was warranted.

2.7.3 Basis for Action

The data demonstrate that the soil at Site 41 is characterized by both lateral and vertical contamination by cPAHs, dieldrin, 4-4’-DDT, and TRPH. Of these contaminants, cPAHs and dieldrin exceed Florida’s industrial SCTLs in Chapter 62-777, Florida Administrative Code (F.A.C.), Table II, and all four contaminants exceed the residential SCTLs up to two orders of magnitude. Given the locations, types, and levels of contaminants discovered, and other general circumstances found at Site 41, it is the Navy’s considered discretionary judgment that some form of remedial action is warranted at this site. Implementing a soil removal action in conjunction with LUCs prohibiting residential land use at Site 41, following additional soil delineation, will allow the Navy to properly and effectively manage future land use at the site and minimize threats to human health or the environment. 2.8 REMEDIAL ACTION OBJECTIVES

Remedial Action Objectives (RAOs) are medium-specific goals that define the objectives for conducting remedial actions, if needed, to protect human health and the environment. RAOs specify the COCs, potential exposure routes and receptors, and acceptable concentrations (i.e., cleanup levels) for a site


15

and provide a general description of what the cleanup will accomplish. RAOs typically serve as the design basis for the remedial alternatives described in Section 2.9. The RAO for Site 41 is as follows:

To protect human health from carcinogenic risks associated with incidental ingestion of, inhalation of, and dermal contact with soil containing cPAHs and dieldrin at concentrations exceeding Florida’s commercial/industrial SCTLs.

Site 41 cleanup goals (CGs), as established in the FS, for the COCs are FDEP SCTLs, as presented in Table 2-3.

TABLE 2-3. SOIL CLEANUP GOALS

COC RESIDENTIAL CG* INDUSTRIAL CG

cPAHs 0.100 0.700

Dieldrin 0.06 0.30 Concentrations in mg/kg *Applicable under Alternative S41-3

Removal of soil at Site 41 with COC concentrations greater than industrial CGs will eliminate unacceptable human health risks for future industrial and construction workers and current lifelong recreational users (because site-specific recreational SCTLs are greater than industrial SCTLs; see Appendix C), and prevention of exposure to soil with COC concentrations greater than residential SCTLs will eliminate unacceptable human health risks for hypothetical future residents.

2.9 DESCRIPTION OF REMEDIAL ALTERNATIVES

To address potential unacceptable human health risks associated with soil at Site 41, a preliminary technology screening evaluation, including the following steps, was conducted in the FS (Tetra Tech, 2011a). The general response actions (GRAs) are presented in Table 2-4. Soil remedial technologies and process options excluded from further analysis included infiltration barriers under the containment GRA because reduction of infiltration is not required to meet RAOs, and in-situ treatment including thermal, physical/chemical, and biological technologies because they were not applicable to all site contaminants or conditions or because they would interfere with future site uses.

TABLE 2-4. GENERAL RESPONSE ACTIONS

GENERAL RESPONSE ACTION TECHNOLOGY PROCESS OPTIONS

No Action None Not applicable

Limited Action LUCs Administrative controls: deeds and site use restrictions

Removal Excavation Excavation

Disposal Landfill Off-base landfilling The technologies and process options retained after detailed screening were assembled into three alternatives. Consistent with the NCP, a no action alternative was evaluated for soil as a baseline for comparison with other alternatives during the comparative analyses. Three remedial alternatives for soil (no action, excavation to meet industrial SCTLs with LUCs, and excavation to meet residential SCTLs) were retained for a detailed comparative analysis in accordance with the NCP. Table 2-5 describes the major components and provides estimated costs for the soil remedial alternatives identified for Site 41.


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TABLE 2-5. SOIL REMEDIAL ALTERNATIVES EVALUATED ALTERNATIVE COMPONENTS DETAILS COST

S41-1: No Action

No action to address contaminated soil and no restrictions on activities.

None No action No cost

S41-2: Excavation to Meet Industrial SCTLs and Off-Site Disposal with LUCs

Excavation and off-site disposal of all soil with COC concentrations exceeding industrial SCTLs and LUCs

Excavation and off-site disposal of soil

Excavation and off-site disposal of approximately 88 cubic yards of soil; collection of confirmation samples from the sidewalls and bottoms of excavated areas; backfilling of excavated areas with clean backfill material, covering with topsoil, and reseeding

Cost

Capital: $80,000

30-Year NPW of O&M: $26,000

30-Year NPW: 106,000

Discount rate: 6%

Time frame: 1 month

LUCs LUCs to restrict future site uses to non-residential activities and to prohibit uncontrolled soil excavation at the site

S41-3: Excavation to Meet Residential SCTLs and Off-Site Disposal

Excavation and off-site disposal of all soil with COC concentrations exceeding residential SCTLs

Excavation and off-site disposal of soil

Excavation and off-site disposal of approximately 847 cubic yards of soil; collection of confirmation samples from the sidewalls and bottoms of excavated areas; backfilling of excavated areas with clean backfill material, covering with topsoil, and reseeding

Cost

Capital: $239,000

30-Year NPW of O&M: $0

30-Year NPW: $239,000 Discount rate: 6%

Time frame: 3 months

2.10 COMPARATIVE ANALYSIS OF ALTERNATIVES

Table 2-6 and text in this section summarize the comparison of the remedial alternatives with respect to the nine CERCLA evaluation criteria outlined in the NCP at 40 Code of Federal Regulations (CFR) 300.430(e)(9)(iii) and categorized as threshold, primary balancing, and modifying criteria. Further information on the detailed comparison of remedial alternatives is presented in the Site 41 FS (Tetra Tech, 2011a). Threshold Criteria Overall Protection of Human Health and the Environment. The no action alternative would not achieve the RAOs and therefore would not protect human health and the environment. This alternative will not be considered further in this ROD. Although soil removal to achieve residential SCTLs, as contemplated under Alternative S41-3, would be the most protective of human health because it would permanently remove all unacceptable risks from exposure to soil COCs, this alternative does not factor in the current and reasonably anticipated future land use (industrial) as is allowed by USEPA guidance (USEPA, 1991). Soil excavation to meet industrial SCTLs would be consistent with current and future use, and when combined with the appropriate LUCs to preclude the possibility of residential uses, would be adequately protective of human health and the environment. Compliance with ARARs. Applicable or Relevant and Appropriate Requirements (ARARs) include any federal or state standards, requirements, criteria, or limitations determined to be either legally applicable or relevant and appropriate to the site or remedial action. Both excavation alternatives evaluated would meet all chemical- and action-specific ARARs to the same general degree. No location-specific ARARs exist for this site.


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TABLE 2-6. SUMMARY OF COMPARATIVE ANALYSIS OF SOIL ALTERNATIVES

CERCLA Criterion S41-1:

No Action

S41-2: Excavation and

Off-Site Disposal to Meet Industrial

SCTLs with LUCs

S41-3: Excavation and

Off-Site Disposal to Meet Residential

SCTLs

Overall Protection of Human Health and the Environment

Compliance With ARARs and TBCs

Long-Term Effectiveness and Permanence

Reduction of Toxicity, Mobility, and Volume

NA

Short-Term Effectiveness

Implementability NA

Capital Cost NPW of O&M NPW

$0 $0 $0

$80,000 $26,000

$106,000

$239,000 $0

$239,000

State Acceptance

Community Acceptance

- High - Medium - Low Primary Balancing Criteria Long-Term Effectiveness and Permanence. Soil excavation to achieve residential SCTLs would have the most long-term effectiveness and permanence because all contaminated soil with COC concentrations greater than residential SCTLs would be removed from the site. Excavation to meet industrial SCTLs would have less long-term effectiveness and permanence than residential excavation because contamination would remain on site, and LUCs would be required to provide continued protectiveness. Reduction in Toxicity, Mobility, or Volume Through Treatment. Neither Alternative S41-2 nor S41-3 would utilize treatment to reduce the toxicity, mobility, or volume of hazardous substances. Because of the type of contamination detected at Site 41 and its relatively low long-term risk based on the current and reasonably anticipated future site use, soil treatment was deemed impracticable and would not be cost effective. In addition, no source constituting principal threats will be addressed within the scope of either alternative. Short-Term Effectiveness. Because of the excavation and off-base transportation of a larger quantity of soil, which would involve a greater opportunity for exposure of remediation workers and the community to contaminated soil, Alternative S41-3 would pose greater short-term risk than S41-2. Under both alternatives, the use of proper personal protective equipment (PPE), monitoring equipment, and observance of Occupational Safety and Health Administration (OSHA) guidelines would address the worker exposure concerns. Potential environmental effects such as dust, storm water erosion, and noise abatement could be managed through control measures implemented during site activities. The industrial


18

excavation alternative would include LUCs and would have additional short-term risks associated with the need to periodically inspect the site. Implementability. Both S41-2 and S41-3 would be relatively easy to implement because resources, equipment, and materials for soil excavation (basic earth-moving equipment) are readily available. Except for procurement of the appropriate disposal facility and arrangement for transportation, these alternatives would not require an extended planning phase or design. Delineation to determine the limits of excavation area would need to be conducted through sampling under each alternative. The industrial excavation alternative, which would include LUCs, would involve additional administrative aspects (inspection and maintenance) but would still be readily implementable. Cost. The estimated present-worth for excavation to achieve industrial SCTLs and LUCs (Alternative S41-2) is $106,000, and the estimated present-worth cost for excavation to achieve residential SCTLs (Alternative S41-3) is $239,000. Modifying Criteria State Acceptance. State involvement has been solicited throughout the CERCLA process for Site 41. FDEP, as the designated state support agency in Florida, concurs with the Selected Remedy. Community Acceptance. No written questions were received during the formal public comment period (January 10 to February 9, 2011) for the Proposed Plan (Tetra Tech, 2011b). No public meeting was requested and therefore, no meeting was held. 2.11 PRINCIPAL THREAT WASTES

The NCP at 40 CFR 300.430(a)(1)(iii)(A) establishes an expectation that treatment will be used to address the principal threats posed by a site wherever practicable. Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained or that would present a significant risk to human health or the environment should exposure occur. A source material is a material that includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface water, or air, or acts as a source for direct exposure. The residual soil contamination at Site 41 is not highly toxic or highly mobile; therefore, principal threat wastes are not present at the site.

2.12 SELECTED REMEDY

2.12.1 Rationale for Selected Remedy

The Selected Remedy for Site 41 at NAS Whiting Field is S41-2, Soil Excavation and Off-Site Disposal to meet FDEP Industrial Cleanup Criteria and LUCs, which was selected because it provides the best balance of tradeoffs with respect to the nine CERCLA evaluation criteria and will allow for continued industrial use of the property. The remedy will meet the RAO by excavating soil with COC concentrations greater than FDEP industrial SCTLs and by implementing LUCs to restrict future site uses to industrial activities and to prohibit uncontrolled soil excavation. The principal factors in the selection of this remedy included the following: The remedy is consistent with the reasonably anticipated future industrial use of the site and will allow

continued use of the area for equipment storage. The remedy achieves protection at a lower cost less than full-scale removal to achieve unlimited use

and unrestricted exposure ($106,000 compared to $239,000).


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2.12.2 Description of Selected Remedy

The Selected Remedy includes two major components: (1) excavation and off-site disposal of contaminated soil to meet FDEP industrial SCTLs; and (2) LUCs to restrict site use to non-residential activities only and to prohibit soil excavation or disturbance. Soil will be excavated from an area of approximately 1,028 square feet to an estimated depth of 2 feet, for a total of approximately 88 cubic yards of soil (see Figure 2-4). The final excavation limits will be determined based on sampling conducted prior to or during preparation of the Remedial Design (RD). Confirmatory samples will be collected from the sidewalls and bottoms of the excavated areas to verify that industrial SCTLs are met. TCLP sampling will be conducted to verify disposal requirements. For costing purposes, it was assumed that all of the soil would meet TCLP limits and not require treatment prior to disposal at a RCRA Subtitle D (non-hazardous) facility. Approximately 88 cubic yards of excavated void will be filled with clean backfill, covered with top soil, and seeded with grass. LUCs will be implemented within the Site 41 boundaries (see Figure 2-4) to limit use of the property and to prohibit soil excavation and disturbance. Consistent with the RAO developed for the site, the specific performance objectives for the LUCs to be implemented at Site 41 are as follows: To prohibit residential or residential-like reuse of the site unless prior written approval is obtained from

the USEPA and FDEP. Prohibited residential or residential-like uses shall include, but are not limited to, any form of housing, child-care facilities, pre-schools, elementary schools, secondary schools, playgrounds, convalescent, or nursing care facilities.

To prohibit the excavation and uncontrolled disturbance of surface and subsurface soil at the site

unless prior written approval is obtained from the USEPA and FDEP.

To maintain the integrity of any existing or future monitoring or remediation system(s) unless prior written approval is obtained from the USEPA and FDEP.

The following generally describes those LUCs that will be implemented at Site 41 to achieve the aforementioned LUC performance objectives: Incorporation of the LUC boundaries and all prohibited land uses into the Base Master Plan. This

LUC will prohibit residential or residential-like reuse of the site and excavation and uncontrolled disturbance of surface and subsurface soil at the site unless prior written approval is obtained from the USEPA and FDEP

Utilization of the installation Excavation Permitting process to require review/approval by the NAS

Whiting Field Public Works Department and implementation of appropriate worker protection practices before any intrusive activities are performed at the site. This LUC will prohibit the excavation and uncontrolled disturbance of surface and subsurface soil at the site and maintain the integrity of any existing or future monitoring or remediation system(s) unless prior written approval is obtained from the USEPA and FDEP.

Placement of appropriate notices and restrictions in any deed of conveyance or lease affecting the

site in the event the property is conveyed or leased to a third party. This LUC will prohibit residential or residential-like reuse of the site unless prior written approval is obtained from the USEPA and FDEP.

Posting of signs at the site advising that any excavation activity must be authorized in advance by the

base environmental department. The size, location, and content of the signs will be specified in the LUC RD. This LUC will prohibit the excavation and uncontrolled disturbance of surface and subsurface soil at the site and maintain the integrity of any existing or future monitoring or remediation system(s) unless prior written approval is obtained from the USEPA and FDEP.

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Site 41 R

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21

LUCs will be implemented and maintained by the Navy until concentrations of hazardous substances in soil decrease to levels that allow for unlimited use and unrestricted exposure. The Navy or any subsequent owners shall not modify, delete, or terminate any LUC without USEPA and FDEP concurrence. The Navy is responsible for implementing, maintaining, reporting on, and enforcing the LUCs described in this ROD. Although the Navy may later transfer these procedural responsibilities to another party by contract, property transfer agreement, or through other means, the Navy shall retain ultimate responsibility for the remedy integrity. Should any LUC remedy fail, the Navy will ensure that appropriate actions are taken to reestablish the remedy’s protectiveness and may initiate legal action to either compel action by a third party(ies) and/or to recover the Navy’s costs for remedying any discovered LUC violation(s). The LUC implementation actions including monitoring and enforcement requirements will be provided in a LUC RD that will be prepared by the Navy as the LUC component of the overall RD. Within 90 days of ROD signature, the Navy shall prepare and submit to USEPA and FDEP for review and approval (pursuant to those Primary Document review procedures stipulated in the NAS Whiting Field FFA) the LUC RD for Site 41 that shall contain implementation and maintenance actions, including periodic inspections. The Navy will maintain, monitor, and enforce the LUCs according to the LUC RD. LUCs have been developed in accordance with the Principles and Procedures for Specifying, Monitoring, and Enforcement of Land Use Controls and Other Post-ROD Actions, per letter dated October 2, 2003, from Raymond F. DuBois, Deputy Under Secretary of Defense (Installations and Environment), to Hon. Marianne Lamont Horinko, Acting Administrator, USEPA. 2.12.3 Cost of Selected Remedy

As noted in Table 2-5, the estimated costs for the Selected Remedy at Site 41 include capital costs (soil excavation, confirmatory sampling, and sign placement) of approximately $80,000, annual costs (annual compliance inspections and 5-year reviews) of approximately $26,000, and a total NPW (at a 6% discount rate) of $106,000 over the projected 30-year term of the LUCs. Detailed costs for the Selected Remedy are presented in Appendix B. 2.12.4 Expected Outcomes of Selected Remedy

It is expected that the Selected Remedy will be protective of human health and the environment while allowing for continued non-residential uses of the land and facilities within the boundaries of Site 41. It is estimated that the RAO for Site 41 will be achieved within approximately 1 month of implementation of the Selected Remedy. Table 2-7 describes how the Selected Remedy mitigates risk and achieves the RAO for Site 41.

TABLE 2-7. HOW SELECTED REMEDY MITIGATES RISK AND ACHIEVES THE RAO RISK RAO COMMENTS

Direct exposure to, ingestion of, and inhalation of contaminated soil

Prevent unacceptable human health risk associated with exposure to soil containing cPAHs and diedrin at concentrations greater than industrial SCTLs

Excavation of soil to meet risk-based industrial SCTLs will remove soil associated with unacceptable risk under an industrial use scenario.

LUCs will limit exposures via ingestion, dermal contact, and inhalation that result in unacceptable risks under a hypothetical future residential use scenario by preventing residential use and by preventing uncontrolled excavation or disturbance of soil from the site.


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2.13 STATUTORY DETERMINATIONS

In accordance with Section 121(b) of CERCLA and the NCP, the Selected Remedy meets the following statutory determinations: Protection of Human Health and the Environment – The Selected Remedy is needed to prevent

estimated current and future risks associated with maintenance and occupational worker exposure to contaminated surface soil. Excavation of soil to achieve industrial SCTLs will be conducted and LUCs will be implemented to ensure current protectiveness. Implementation of the Selected Remedy does not pose any short term risks or cross-media impacts.

Compliance with ARARs – The Selected Remedy will attain all identified federal and state ARARs,

as presented in Appendix A.

Cost-Effectiveness – The Selected Remedy is the most cost-effective alternative that allows for continued industrial use of the property and represents the most reasonable value for the money. The costs are proportional to overall effectiveness by achieving an adequate amount of long-term effectiveness and permanence within a reasonable time frame. Detailed costs for the Selected Remedy are presented in Appendix B.

Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource

Recovery Technologies to the Maximum Extent Practicable – The Selected Remedy represents the maximum extent to which permanent solutions and alternative treatment technologies can be used in a practical manner at Site 41. Due to the relatively broadly distributed soil, contaminated with low levels of hazardous substances, for which treatment does not represent the best balance of options, and the current and reasonably anticipated future use of the site, treatment alternatives were not evaluated for Site 41 in the FS. Excavation and off-site disposal of soil with COC concentrations exceeding commercial/industrial SCTLs provides the best balance of tradeoffs for long-term effectiveness and permanence with ease of implementation for a reasonable cost.

Preference for Treatment as a Principal Element – Treatment is not a principal element of the

Selected Remedy for soil at Site 41. Due to the relatively broadly distributed soil, contaminated with low levels of hazardous substances, for which treatment is not the best option; the current and reasonably anticipated future use of the site; and because there are no principal threat wastes at the site, the Selected Remedy does not meet the statutory preference for treatment.

Five-Year Review Requirement – Because this remedy will result in COCs remaining on site in

excess of levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within 5 years after initiation of remedial action and every 5 years thereafter to ensure that the remedy is protective of human health and the environment. In addition, annual LUC compliance inspections will be conducted.

2.14 DOCUMENTATION OF SIGNIFICANT CHANGES

CERCLA Section 117(b) requires an explanation of significant changes from the selected remedy presented in the Proposed Plan (Tetra Tech, 2011b) that was published for public comment. Although the opportunity for a public meeting was provided as stated in the Navy’s public notice, none was requested, and no written comments, concerns, or questions were received by the Navy, USEPA, or FDEP during the public comment period.


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3.0 RESPONSIVENESS SUMMARY

3.1 STAKEHOLDER COMMENTS AND LEAD AGENCY RESPONSES

As stated above, a public meeting was not requested, and no written comments, concerns, or questions were received during the public comment period. 3.2 TECHNICAL AND LEGAL ISSUES

No technical or legal issues associated with the Site 41 ROD were identified.


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4.0 REFERENCES

Florida Department of Environmental Protection (FDEP), 2005. Soil Cleanup Target Levels (SCTLs). Chapter 62-777, Florida Administrative Code (F.A.C.). April. Tetra Tech, Inc. (Tetra Tech), 2010. Remedial Investigation Report for Surface and Subsurface Soil, OU 27 - Site 41, Naval Air Station Whiting Field, Milton, Florida. Prepared for NAVFAC SE, Jacksonville, Florida. April. Tetra Tech, 2011a. Feasibility Study for OU 27 – Site 41 Surface and Subsurface Soil, Naval Air Station Whiting Field, Milton, Florida. Prepared for NAVFAC SE, Jacksonville, Florida. March. Tetra Tech, 2011b. Proposed Plan for OU 27 – Site 41 Surface and Subsurface Soil, Naval Air Station Whiting Field, Milton, Florida. Prepared for NAVFAC SE, Jacksonville, Florida. March. United States Environmental Protection Agency (USEPA) 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA. USEPA, 1991. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions, OSWER Directive 9355.0-30, Don R. Clay, April. USEPA, 2001. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment) Interim Guidance, Office of Emergency and Remedial Response, Washington D.C., September. USEPA, 2008. Regional Screening Levels (Soil Screening Levels). USEPA Region 4, Atlanta, GA. April.


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ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement B(a)P Benzo(a)pyrene bls Below land surface CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CG Cleanup goal COC Contaminant of concern COPC Contaminant of potential concern cPAH Carcinogenic polynuclear aromatic hydrocarbon CSF Cancer slope factor CSM Conceptual Site Model CTE Central tendency exposure DDD 4,4-dichlorodiphenyldichlorethane DDE 4,4-dichlorodiphenyldichloroethylene DDT 4,4-dichlorodiphenyltrichloroethane DPT Direct push technology EPC Exposure point concentration ERA Ecological risk assessment ER, N Environmental Restoration, Navy F.A.C. Florida Administrative Code FDEP Florida Department of Environmental Protection FFA Federal Facility Agreement FID Flame ionization detector FS Feasibility Study GRA General Response Action HHRA Human health risk assessment HQ Hazard quotient ILCR Incremental lifetime cancer risk IR Installation Restoration LUC Land use control mg/kg Milligram per kilogram NAS Naval Air Station NCP National Oil and Hazardous Substances Pollution Contingency Plan NPW Net present worth O&M Operation and maintenance OSHA Occupational Safety and Health Administration OU Operable Unit PAH Polynuclear aromatic hydrocarbon PCB Polychlorinated biphenyl PSC Potential Source of Contamination PPE Personal protective equipment RAB Restoration Advisory Board RAO Remedial Action Objective RD Remedial Design RfD Reference dose RI Remedial Investigation RME Reasonable maximum exposure ROD Record of Decision SARA Superfund Amendments and Reauthorization Act SCTL Soil Cleanup Target Level SMP Site Management Plan SPLP Synthetic Precipitation Leaching Procedure


26

ACRONYMS (CONT.)

SSL Soil Screening Level SVOC Semivolatile organic compound TAL Target Analyte List TCL Target Compound List TCLP Toxicity Characteristic Leaching Procedure TRPH Total recoverable petroleum hydrocarbons UCL Upper confidence limit USDA United States Department of Agriculture USEPA United States Environmental Protection Agency UST Underground storage tank VOC Volatile organic compound

Appendix A ARARs Table for Selected Remedy

A-1

ARARs to be Met by the Selected Remedy

Chemical-Specific ARARs

NAS Whiting Field Site 41

Action/Media Requirement Prerequisite Citation

Removal of contaminated soil and sediment for industrial use

Specifies Soil Cleanup Target Levels (CTLs) for site rehabilitation. F.A.C. 62-777 Table II lists the cleanup levels for industrial direct exposure.

Dieldrin – 0.3 milligrams per kilogram (mg/kg)

cPAH – 0.7 milligrams per kilogram (mg/kg)

Rehabilitation (i.e., remediation) of site contaminated soil and sediment – Relevant and Appropriate

F.A.C. 62-777, Table II

Soil Cleanup Target Levels

Action-Specific ARARs


Action Requirement Prerequisite Citation

General Construction Standards — All Land-disturbing Activities (i.e., excavation, clearing, grading, etc.)

Control of storm water runoff from soil disturbing activities

Must comply with the substantive provisions in the “Generic Permit for Stormwater Discharge from Large and Small Construction Activities,” document number 62-621.300(4)(a), issued by the FDEP and effective February 17, 2009. Requires development storm water pollution prevention plan and implementation of best management practices and erosion and sedimentation controls for stormwater runoff to ensure protection of the surface waters of the state.

Note: Plan would be part of CERCLA document such as Removal Action Work Plan.

Stormwater discharges from large and small construction activities to surface waters of the State as defined in Section 403.031, F.S. – Relevant and Appropriate

F.A.C. 62-621.300(4)(a)

Generic Permit for Stormwater Discharge from Large and Small Construction Activities

A-2




Control of Fugitive Dust No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity, including vehicular movement; transportation of materials; construction, alteration, demolition or wrecking; or industrially related activities such as loading, unloading, storing or handling; without taking reasonable precautions to prevent such emissions.

Land disturbing activity that has potential for unconfined emissions of particulate matter – Applicable

F.A.C. 62-296.320(4)(c)

General Pollutant Emission Limiting Standards

Waste Characterization – Primary Waste (e.g., excavated soils/sediments, debris) and Secondary Wastes

(e.g., contaminated PPE or treatment residuals)

Characterization of solid waste (all primary and secondary wastes)

Must determine if solid waste is a hazardous waste using the following method:

Should first determine if waste is excluded from regulation under 40 C.F.R. 261.4; and

Must then determine if waste is listed as a hazardous waste under subpart D 40 C.F.R. Part 261.

Generation of solid waste as defined in 40 C.F.R. 261.2 – Applicable

40 C.F.R. 262.11(a) and (b)1

F.A.C. 62-730.160

Must determine whether the waste is (characteristic waste) identified in subpart C of 40 C.F.R. part 261by either:

(1) Testing the waste according to the methods set forth in subpart C of 40 C.F.R. part 261, or according to an equivalent method approved by the Administrator under 40 C.F.R. 260.21; or

(2) Applying knowledge of the hazard characteristic of

Generation of solid waste which is not excluded under 40 C.F.R. 261.4(a) – Applicable

40 C.F.R. 262.11(c)

F.A.C. 62-730.160

1The NCP definitions of “applicable” or “relevant and appropriate” requirements at 40 C.F.R. § 300.5 include only those state environmental standards that are more stringent than the federal standards. In cases where the state regulations are part of a federally-authorized program, the state regulations are recognized as federal requirements. Both the federal and state citations are listed here to demonstrate equivalence between the federal and state citations.

A-3




the waste in light of the materials or the processes used.

Must refer to Parts 261, 262, 264, 265, 266, 268, and 273 of Chapter 40 for possible exclusions or restrictions pertaining to management of the specific waste.

Generation of solid waste which is determined to be hazardous waste – Applicable

40 C.F.R. 262.11(d)

F.A.C. 62-730.160

Characterization of hazardous waste (all primary and secondary wastes)

Must obtain a detailed chemical and physical analysis on a representative sample of the waste(s), which at a minimum contains all the information that must be known to treat, store, or dispose of the waste in accordance with pertinent sections of 40 C.F.R. 264 and 268.

Generation of RCRA hazardous waste for storage, treatment or disposal – Applicable

40 C.F.R. 264.13(a)(1)

F.A.C. 62-730.180(1)

Determinations for management of hazardous waste

Must determine each EPA Hazardous Waste Number (waste code) applicable to the waste in order to determine the applicable treatment standards under 40 C.F.R. 268 et seq.

Note: This determination may be made concurrently with the hazardous waste determination required in Sec. 262.11 of this chapter.

Generation of hazardous waste for storage, treatment or disposal – Applicable

40 C.F.R. 268.9(a)

F.A.C. 62-730.183

Must determine the underlying hazardous constituents [as defined in 40 C.F.R. 268.2(i)] in the characteristic waste.

Generation of RCRA characteristic hazardous waste (and is not D001 non –wastewaters treated by CMBST, RORGS, or POLYM of Section 268.42 Table 1) for storage, treatment or disposal – Applicable

40 C.F.R. 268.9(a)

F.A.C. 62-730.183

A-4




Determinations for management of hazardous waste

Must determine if the hazardous waste meets the treatment standards in 40 C.F.R. 268.40, 268.45, or 268.49 by testing in accordance with prescribed methods or use of generator knowledge of waste.

Note: This determination can be made concurrently with the hazardous waste determination required in 40 C.F.R. 262.11.

Generation of hazardous waste for storage, treatment or disposal – Applicable

40 C.F.R. 268.7(a)

F.A.C. 62-730.183

Must comply with the special requirements of 40 C.F.R. 268.9 in addition to any applicable requirements in C.F.R. 268.7.

Generation of waste or soil that displays a hazardous characteristic of ignitability, corrosivity, reactivity, or toxicity for storage, treatment or disposal – Applicable

40 C.F.R. 268.7(a)

F.A.C. 62-730.183

Waste Storage – Primary Waste (e.g., excavated soils) and Secondary Wastes

(e.g., contaminated PPE) Temporary on–site storage of hazardous waste in containers

A generator may accumulate hazardous waste at the facility provided that:

waste is placed in containers that comply with 40 C.F.R. 265.171 –173; and

the date upon which accumulation begins is clearly marked and visible for inspection on each container;

container is marked with the words “hazardous waste”; or

Accumulation of RCRA hazardous waste on site as defined in 40 C.F.R. 260.10 – Applicable

40 C.F.R. 262.34(a);

40 C.F.R. 262.34(a)(1)(i);

40 C.F.R. 262.34(a)(2) and (3)

F.A.C. 62-730.160

A-5




container may be marked with other words that identify the contents.

Accumulation of 55 gal. or less of RCRA hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) at or near any point of generation – Applicable

40 C.F.R. 262.34(c)(1)

F.A.C. 62-730.160

Use and management of hazardous waste in containers

If container is not in good condition (e.g. severe rusting, structural defects) or if it begins to leak, must transfer waste from this container to a container that is in good condition. Must use container made or lined with materials compatible with waste to be stored so that the ability of the container to contain is not impaired. Containers must be closed during storage, except when necessary to add/remove waste. Container must not opened, handled and stored in a manner that may rupture the container or cause it to leak.

Storage of RCRA hazardous waste in containers – Applicable

40 C.F.R. 265.171

F.A.C. 62-730.180(2) 40 C.F.R. 265.172 F.A.C. 62-730.180(2) 40 C.F.R. 265.173(a) and (b) F.A.C. 62-730.180(2)

Storage of hazardous waste in container area

Area must have a containment system designed and operated in accordance with 40 C.F.R. 264.175(b)

Storage of RCRA hazardous waste in containers with free liquids – Applicable

40 C.F.R. 264.175(a)

F.A.C. 62-730.180(1)

Area must be sloped or otherwise designed and operated to drain liquid resulting from precipitation, or

Containers must be elevated or otherwise protected from contact with accumulated liquid.

Storage of RCRA–hazardous waste in containers that do not contain free liquids (other than F020, F021, F022, F023,F026 and F027) – Applicable

40 C.F.R. 264.175(c)(1) and (2)

F.A.C. 62-730.180(1)

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Closure performance standard for RCRA container storage unit

Must close the facility (e.g., container storage unit) in a manner that:

Minimizes the need for further maintenance;

Controls minimizes or eliminates to the extent necessary to protect human health and the environment, post –closure escape of hazardous waste, hazardous constituents, leachate, contaminated run –off, or hazardous waste decomposition products to the ground or surface waters or the atmosphere; and

Complies with the closure requirements of subpart, but not limited to, the requirements of 40 C.F.R. 264.178 for containers.

Storage of RCRA hazardous waste in containers – Applicable

40 C.F.R. 264.111

F.A.C. 62-730.180(1)

Closure of RCRA container storage unit

At closure, all hazardous waste and hazardous waste residues must be removed from the containment system. Remaining containers, liners, bases, and soils containing or contaminated with hazardous waste and hazardous waste residues must be decontaminated or removed.

[Comment: At closure, as throughout the operating period, unless the owner or operator can demonstrate in accordance with40 C.F.R. 261.3(d) of this chapter that the solid waste removed from the containment system is not a hazardous waste, the owner or operator becomes a generator of hazardous waste and must manage it in accordance with all applicable requirements of parts 262 through 266 of this chapter].

Storage of RCRA hazardous waste in containers in a unit with a containment system – Applicable

40 C.F.R. 264.178

F.A.C. 62-730.180(1)

Storage and processing of non-hazardous waste

No person shall store, process, or dispose of solid waste except as authorized at a permitted solid waste management facility or a facility exempt from permitting under this chapter.

No person shall store, process, or dispose of solid waste in

Management and storage of solid waste – Applicable

F.A.C. 62 701.300(1)(a) and (b)

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a manner or location that causes air quality standards to be violated or water quality standards or criteria of receiving waters to be violated.

Waste Treatment and Disposal – Primary Waste (e.g., excavated soils) and

Secondary Wastes (e.g., contaminated PPE) Disposal of RCRA hazardous waste in a land-based unit

May be land disposed if it meets the requirements in the table “Treatment Standards for Hazardous Waste” at 40 C.F.R. 268.40 before land disposal.

Land disposal, as defined in 40 C.F.R. 268.2, of restricted RCRA waste – Applicable

40 C.F.R. 268.40(a)

F.A.C. 62-730.183

All underlying hazardous constituents [as defined in 40 C.F.R. 268.2(i)] must meet the Universal Treatment Standards, found in 40 C.F.R. 268.48 Table UTS prior to land disposal

Land disposal of restricted RCRA characteristic wastes (D001 –D043) that are not managed in a wastewater treatment system that is regulated under the CWA, that is CWA equivalent, or that is injected into a Class I nonhazardous injection well – Applicable

40 C.F.R. 268.40(e)

F.A.C. 62-730.183

Disposal of RCRA hazardous waste in a land-based unit

To determine whether a hazardous waste identified in this section exceeds the applicable treatment standards of 40 C.F.R. 268.40, the initial generator must test a sample of the waste extract or the entire waste, depending on whether the treatment standards are expressed as concentration in the waste extract or waste, or the generator may use knowledge of the waste.

If the waste contains constituents (including UHCs in the

Land disposal of RCRA toxicity characteristic wastes (D004 –D011) that are newly identified (i.e., wastes, soil, or debris identified by the TCLP but not the Extraction Procedure) – Applicable

40 C.F.R. 268.34(f)

F.A.C. 62-730.183

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characteristic wastes) in excess of the applicable UTS levels in 40 C.F.R. 268.48, the waste is prohibited from land disposal, and all requirements of part 268 are applicable, except as otherwise specified.

Disposal of RCRA hazardous waste debris in a land–based unit (i.e., landfill)

Must be treated prior to land disposal as provided in 40 C.F.R. 268.45(a)(1)–(5) unless EPA determines under 40 C.F.R. 261.3(f)(2) that the debris no longer contaminated with hazardous waste or the debris is treated to the waste –specific treatment standard provided in 40 C.F.R. 268.40 for the waste contaminating the debris.

Land disposal, as defined in 40 C.F.R. 268.2, of restricted RCRA–hazardous debris – Applicable

40 C.F.R. 268.45(a)

F.A.C. 62-730.183

Disposal of RCRA –hazardous waste soil in a land–based unit

Must be treated according to the alternative treatment standards of 40 CFR 268.49(c) or according to the UTSs specified in 40 CFR 268.48 applicable to the listed and/or characteristic waste contaminating the soil prior to land disposal

Land disposal, as defined in 40 CFR 268.2, of restricted hazardous soils – Applicable

40 CFR 268.49(b)

F.A.C. 62-730.183

Waste Transportation – Primary and Secondary Wastes

Transportation of hazardous waste on–site

The generator manifesting requirements of 40 C.F.R. 262.20262.32(b) do not apply. Generator or transporter must comply with the requirements set forth in 40 C.F.R. 263.30 and 263.31 in the event of a discharge of hazardous waste on a private or public right–of–way.

Transportation of hazardous wastes on a public or private right–of–way within or along the border of contiguous property under the control of the same person, even if such contiguous property is divided by a public or private right–of–way Applicable

40 C.F.R. 262.20(f)

F.A.C. 62-730.160

Transportation of hazardous waste off–site

Must comply with the generator standards of Part 262 including 40 C.F.R. 262.2023 for manifesting, Sect. 262.30 for packaging, Sect. 262.31 for labeling, Sect. 262.32 for marking, Sect. 262.33 for placarding,

Preparation and initiation of shipment of hazardous waste off–site Applicable

40 C.F.R. 262.10(h);

F.A.C. 62-730.160

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Transportation of hazardous materials

Shall be subject to and must comply with all applicable provisions of the HMTA and HMR at 49 C.F.R. 171180 related to marking, labeling, placarding, packaging, emergency response, etc.

Any person who, under contract with a department or agency of the federal government, transports “in commerce,” or causes to be transported or shipped, a hazardous material Applicable

49 C.F.R. 171.1(c)

Transportation of samples (i.e. contaminated soils and wastewaters)

Are not subject to any requirements of 40 C.F.R. Parts 261 through 268 or 270 when:

the sample is being transported to a laboratory for the purpose of testing; or

the sample is being transported back to the sample collector after testing

the sample is being stored by sample collector before transport to a lab for testing

Samples of solid waste or a sample of water, soil for purpose of conducting testing to determine its characteristics or composition - Applicable

40 C.F.R. 261.4(d)(1)(i)–(iii)

F.A.C. 62-730.030

In order to qualify for the exemption in paragraphs (d)(1)(i) and (ii), a sample collector shipping samples to a laboratory must:

Comply with U.S. DOT, U.S. Postal Service, or any other applicable shipping requirements

Assure that the information provided in (1) thru (5) of this section accompanies the sample.

Package the sample so that it does not leak, spill, or vaporize from its packaging.

40 C.F.R. 261.4(d)(2)(i)(A) and (B)

F.A.C. 62-730.030

Notes: ARAR = applicable or relevant and appropriate requirement

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C.F.R. = Code of Federal Regulations F.A.C. = Florida Administrative Code, Chapters as specified F.S. = Florida Statutes PCB = polychlorinated biphenyl PPE = personal protection equipment

Appendix B Cost Estimate

B-1

B-2

B-3

B-4

B-5

Appendix C Risk Tables

C-1

C-2

C-3

C-4

C-5

C-6

C-7

C-8

C-9

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Appendix D Response To Comments

D-1

RESPONSE TO USEPA COMMENTS ON DRAFT ROD FOR SITE 41

FORMER PESTICIDE STORAGE BUILDING 1485C

NAS WHITING FIELD

USEPA comments issued September 23, 2010, from Mr. Craig Benedikt, USEPA, to Mr. Benjamin Kissam, RPM NAVFAC SE.

1. In some places within the document, the terms “unrestricted use and unlimited exposure” are used;

and in other places, the terms “unlimited use and unrestricted exposure” are used. Please decide

which terms are appropriate and revise the document accordingly.

Response: Agreed, the document has been updated so the terms “unrestricted use and unlimited exposure” are used consistently throughout the document.

2. Section 1.3, Page 2: Please delete “actual or threatened” in the first sentence. The presence of

contamination has been determined through sampling and analysis.

Response: This change has been made.

3. Section 1.4, Page 2: Please delete the word “potential” in the first sentence under the bulleted

items. In addition, please add the following to the end of the first sentence: “…and to preclude any

activities that may disturb the soils without prior authorization.”

Response: These changes have been made.

4. Section 2.1, Page 4: The fourth sentence in the second paragraph should also indicate that an

unknown quantity of soil was removed as well as the building materials and the concrete slab.

Response: Agreed, the sentence has been revised as follows:

“Following the fire, cleanup activities at the site included the removal of all building materials, the concrete slab flooring, and an unknown quantity of soil.”

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5. Section 2.3, Page 6: Please add “the” between “with” and “NAS” in the first full sentence at the top

of the page.


6. Section 2.4, Page 6: Please state that the FFA became effective on July 10, 2009, in the first

sentence of this section. The third sentence of this section states that Site 31 required no further

investigation; however, a No Further Action ROD was signed for Site 31 in September of 2002.

Response: Agreed, the subject sentences of Section 2.4 have been revised as follows:

“…under CERCLA authority pursuant to the Federal Facility Agreement (FFA) dated March 9, 2009 (effective July 10, 2009).” and;

“A No Further Action ROD for soil at Site 31 was signed in September 2002, …”

7. Section 2.5, Page 6: The second sentence of this section states that the source of contamination is

unknown; however as previously stated in the text of the ROD, the former building was utilized for

pesticide storage. The fact that the building was utilized to store pesticides and pesticide

contamination has been found in onsite soils points to clear evidence of a source of contamination.

Please delete the word “the” following “at” in the second sentence of Section 2.5.1.

Response: Agreed, the second sentence of Section 2.5 has been revised as follows:

“The source of contamination at Site 41 is likely related to pesticide and equipment storage, and potential contaminant release and transport mechanisms include precipitation infiltration and migration to subsurface soil and runoff and erosion of contaminated soil via wind and/or stormwater runoff.”

8. Section 2.6, Page 9: Please add the following to the end of the last sentence in the second full

paragraph: “…with input from the EPA and FDEP.”


9. Section 2.7.1, Page 10: Please add the word “The” to the beginning of the first sentence in the

“Toxicity Assessment” subsection.


D-3

10. Section 2.7.1, Page 11: Please remove all references to other causes of cancer in the second

paragraph of the “Risk Characterization” subsection. This information is not relevant to the discussion

and uses a different set of scientific data to determine risk.

Response: The second paragraph of the “Risk Characterization” subsection has been revised as follows:

“For carcinogens, risks are generally expressed as the incremental probability of an individual developing cancer over a lifetime as a result of exposure to the carcinogen. These calculated risks are probabilities that are usually expressed in scientific notation (e.g., 1 x 10-6). An excess lifetime cancer risk of 1 x 10-6

under an RME scenario indicates that an individual experiencing the reasonable maximum exposure estimate has a 1 in 1 million chance of developing cancer as a result of site-related exposure. USEPA’s generally acceptable risk range for site-related exposures is 1 in 10,000 to 1 in 1 million (1 x 10-4 to 1 x 10-6) and FDEP has a target risk of 1 in 1 million (1 x 10-6). ”

11. Section 2.7.3, Page 12: Please add “in conjunction with LUCs” in the first sentence of the second

paragraph between “action” and “allowing”.


12. Section 2.10, Page 15: In the fourth sentence of the “Implementability” subsection, please change

“includes” to “include” and change “LUC” to “LUCs”. In the “Cost” subsection on this page, please

add “(Alternative S41-2)” following “LUCs” in the first part of the sentence; and please add

“(Alternative S41-3)” after “SCTLs” in the second part of the sentence.


13. Section 2.12.2, Page 16: In the first bulleted item, delete the word “Navy” since the Navy would not

need to prior written approval from itself before changing site usage. In the second bulleted item,

please insert “from” between “soil” and “the” and delete the word “Navy”. In the third bulleted item,

please delete the word “Navy”.


D-4

The following comments were provided by Martha Brock, Region 4 Associate Legal Counsel:

Comments:

1. Section 1.2, page 2. See comment 2, and please move the last sentence in this section to the to-be-

added description, in Section 1.4, of the overall site cleanup strategy. The last sentence, which states

that the groundwater will be addressed in a later action, fits better there.

Response: These changes have been made (see response to Comment #2 below).

2. Section 1.4, page 2. EPA Guidance indicates that this section should contain a brief explanation of

the overall site cleanup strategy. Please include a brief description of how this action fits into the

overall site management plan. That is, please describe the intended sequence and timing of the

operable units and identify the selected performance standards. This description could be placed

immediately prior to the last sentence in this section.

Response: Agreed, the following text has been added to Section 1.4 on page 2:

“Environmental work at Site 41 is part of the Navy’s ongoing Installation Restoration Program that includes 27 OUs at NAS Whiting Field. This is a Department of Defense program to investigate and, if necessary, cleanup conditions related to suspected past releases of hazardous materials at military facilities. Currently, 24 of the 27 OUs at NAS Whiting Field have final RODs detailing remedy selection and remedial implementation at those OUs has either been completed or is ongoing.”

3. Section 1.4, page 2. EPA Guidance indicates that this section should include a brief description of

how the selected remedy addresses source materials that constitute principal threats. Since this site

does not contain principal threats, but does contain lower threat source material which are being

removed to return the site to its current and reasonably anticipated land use, a statement to that

effect would be consistent with the remedial action and EPA Guidance.

Response: The last sentence of Section 1.4 on page 2 has been edited as follows:

“Implementation of the remedy at Site 41 will remove low threat source material and return the site to its reasonably anticipated land use allowing industrial/commercial reuse of the site, which is consistent with current use and the overall cleanup strategy for NAS Whiting Field of restoring sites to support base operations.”

D-5

4. Section 1.4, page 2. In this section and elsewhere, the discussion distinguishes between residential

versus non-residential uses in some places and between residential and industrial/commercial in

others. Please clarify whether any other use than residential is protective after remediation; for

instance, is recreational use protective?

Response: Only industrial/commercial land use will be protective at Site 41 after remediation.

5. Section 1.5, page 2. Please make the following change and add the following statement after “make

treatment impracticable; . . “. Please change the semi-colon in that sentence to a period, and add the

new sentence immediately after the new period:

“In addition, no source constituting principal threats will be addressed within the scope of this action.”


6. Section 2.2, page 5. EPA Guidance indicates that an important piece of information is whether the

site was in operation before or after the effective date of key RCRA regulations, such as November

19, 1980. Please clarify whether this site was in operation at that time.

Response: Agreed, the following sentence has been added to Section 2.1 – Site Name, Location, and Brief Description:

“The site has been in use since the early 1960s.”

7. Section 2.5, page 6. The text refers to Figure 2-2 as the Conceptual Site Model. Please clarify which

part of Figure 2-2 demonstrates the origin of the contamination. I would have presumed that the figure

would have shown past storage, mixing and handling of pesticides as the mechanisms likely to have

resulted in release of hazardous substances to the environment. The text states that the source of the

contamination is unknown, but that the source may have been related to past pesticide storage, etc.,.

Please change “are unknown” to “are not precisely known” and add “in terms of specific timing,

incident or process.” In order to be consistent with the following section, the text should also reflect

that it is likely (not merely “may”) that the past storage, mixing and handling of pesticide at this former

pesticide storage facility was the source of the contamination at this site. Please change “may” to “is

likely.”

D-6

Response: Figure 2-2 has been updated and the subject text in Section 2.5 has been revised as described in the response to Comment #7 (from Craig Benedikt) above. In addition, the first paragraph of Section 2.5.2 has been revised as follows:

“The RI concluded that the release of contaminants at Site 41 appears to have resulted from storage and disposal of pesticides used for maintenance of the base grounds and other undocumented activities at the site. The source and nature of materials and the time of disposal are not precisely known in terms of specific timing, incident or process.”

8. Section 2.7.1, page 10. In the first full paragraph, please add the following parenthetical after

“unlikely”, (i.e., is not the reasonably anticipated land use).”


9. Section 2.7.1, page 11. The second full paragraph contains a couple of statements about the

chance of developing cancer from other causes and that such risk has been estimated to be as high

as one in three. The other causes mentioned are smoking and “too much sun.” This report is not

intended to summarize the science of societal cancer risks, and it is suggested that these statements

be deleted. If, however, this report is going to provide a summary of societal cancer risks, please be

more comprehensive, and include the “al low as,” median and mean statistics, providing the citations

for conclusions and statistics.

Response: Section 2.7.1 has been revised as requested (see Response to Comment #10 from Craig Benedikt above).

10. Section 2.7.3, page 12. In the first paragraph, please add “, as a policy matter, ” after “judgment

that.”

Response: This change was not made as it does not reflect Navy policy. The first paragraph in Section 2.7.3 has been revised per the language agreed upon by USEPA, FDEP, and the Navy (see March 7, 2011 e-mail from Craig Benedikt) and now reads as follows: “The data demonstrate that the soil at Site 41 is characterized by both lateral and vertical contamination by cPAHs, dieldrin, 4-4’-DDT, and TRPH. Of these contaminants, cPAHs and dieldrin exceed Florida’s industrial SCTLs in Chapter 62-777, Florida Administrative Code (F.A.C.), Table II, and all four contaminants exceed the residential SCTLs up to two orders of magnitude. Given the locations, types, and levels of contaminants discovered, and other general circumstances found at Site 41, it is the Navy’s considered discretionary judgment that some form of remedial action is warranted at this site.”

D-7

11. Section 2.8, page 12. It may be confusing to the reader to include the residential numbers in Table

2-3, since the title is Soil Cleanup Goals. It is not a goal of this action to achieve the residential soil

cleanup number. Perhaps text and/or highlighting could be added to the table that would clarify this

point. The main body text makes the point, but it remains confusing why residential values are labeled

cleanup goals.

Response: Agreed, a note has been added to Table 2-3 indicating that the Residential CGs are applicable to Alternative S41-3.

12. Section 2.8, page 12. In the last paragraph, please change “SCLTs” to “SCTLs”.


13. Section 2.10, page 14. In “Threshold Criteria,” second paragraph, the ROD states that Alternative

S41-3 “does not appropriately factor in the current and reasonably anticipated future land use

(industrial).” Please change this to read, “does not factor in the current and reasonably future land

use (industrial) as is allowed by EPA guidance. Role of the Baseline Risk Assessment in Superfund

Remedy Selection Decisions, OSWER Directive 9355.0-30, Don R. Clay, April 22, 1991. The

guidance does not discourage the evaluation of an unrestricted use scenario; it states that the

unrestricted use scenario is not justified in all instances, as where the probably of residential use is

small, and that evaluation of an unrestricted use scenario is not required in all instances, for example,

where the reasonably anticipated land use is not residential/unrestricted.

Response: The second paragraph has been revised to read as follows:

“Although soil removal to achieve residential SCTLs, as contemplated under Alternative S41-3, would be the most protective of human health because it would permanently remove all unacceptable risks from exposure to soil COCs, this alternative does not factor in the current and reasonably anticipated future land use (industrial) as is allowed by USEPA guidance (USEPA, 1991). Soil excavation to meet industrial SCTLs would be consistent, and when combined with the appropriate LUCs to preclude the possibility of residential uses, would be adequately protective of human health and the environment.”

14. Section 2.10, page 15. In the section discussing reduction in toxicity, the last sentence concludes

that treatment was deemed unnecessary. CERCLA Section 121 contains a statutory preference for

treatment to reduce toxicity, mobility or volume through treatment. Deeming it unnecessary would be

an inadequate justification for not meeting this preference.

Response: The second sentence of the subsection has been revised as follows:

D-8

“Because of the type of contamination detected at Site 41 and its relatively low long-term risk based on the current and reasonably anticipated future site use, soil treatment was deemed impracticable and would not be cost effective.”

15. Section 2.12.2, page 17. In the last paragraph, last line, please change “review and comment” to

“review and approval” since EPA has approval authority for Remedial Design documents under the

Whiting FFA.


16. Section 2.13, page 18. If a remedy is selected that does not employ treatment or resource recovery

technologies, the explanation of the rationale used in the decision under this statutory finding must

include the reasons for finding treatment to be impracticable. The explanation for not utilizing

permanent solutions and treatment technologies becomes difficult when an alternative did not

evaluate treatment for comparison. If there is additional information that underlay the decision not to

evaluate a treatment alternative, please provide this as justification for the impracticability for such

technologies.

Response: There is not additional information underlaying the decision not to evaluate a treatment alternative.

17. Appendix A. The ARARs appear to be largely correct. Please note, however, that EPA generally

requests that a column entitled “Prerequisite” be included so that all may clearly understand the

action/location/chemical that triggers the requirement. Instead of a “Prerequisite” column, there is one

entitled, “Comment,” which in some cases appears to describe the trigger, but not in all cases. Please

replace “Comment” with “Prerequisite” and verify that the text accurately describes the prerequisite or

triggering action for the requirement


D-9

RESPONSE TO FDEP COMMENTS ON DRAFT ROD FOR SITE 41

FORMER PESTICIDE STORAGE BUILDING 1485C

NAS WHITING FIELD

FDEP comments issued September 9, 2010, from Mr. John Winters, FDEP, to Mr. Tread Kissam, RPM NAVFAC SE.

1. Overall Comment: Please match the data in the ROD to the latest version of the site's Feasibility

Study (FS). After a quick scan of both documents I know the estimates of the excavation sizes are

slightly different. Other things may need to be edited as well.

Response: These changes and updates have been made.

2. Description of Selected Remedy, Page 2: In the first sentence of the main paragraph please

remove "industrial SCTLs" and replace with "FDEP direct exposure commercial/industrial soil cleanup

target levels (SCTLs)".


3. Statutory Determinations, Page 2, Second paragraph: At the end of this paragraph please talk

about the yearly LUC reviews that will be conducted as well.

Response: The following text has been added to this section of the ROD on Page 3:

“In addition, annual LUC compliance inspections will be conducted.”

4. Site History and Enforcement Activities, Page 5, Table 2-1: In the RI Report and FS row please

add a comment mentioning additional soil delineation is required prior to completing any remedy at

the site.

Response: The following text has been added to Table 2-1 in the requested row under the “Activities” column:

“Additional soil delineation will be required prior to implementation of a remedy.”

D-10

5. Community Participation, Page 6, Third paragraph: Complete these dates when they are known.

Response: The dates (January 10 to February 9, 2011) have been updated in the text.

6. Basis for Action, Page 12, First paragraph: Please rewrite the second sentence to something like

"Of these contaminants, cPAHs and dieldrin exceed the FDEP industrial SCTLs in Chapter 62-777,

Florida Administrative Code (FAC.), Table II, and all contaminants exceed FDEP residential SCTLs

by up to two orders of magnitude".

Response: The sentence has been revised per the language agreed upon by USEPA, FDEP, and the Navy (see March 7, 2011 e-mail from Craig Benedikt) and now reads as follows:

“Of these contaminants, cPAHs and dieldrin exceed Florida’s industrial SCTLs in Chapter 62-777, Florida Administrative Code (F.A.C.), Table II, and all four contaminants exceed the residential SCTLs up to two orders of magnitude.”

7. Basis for Action, Page 12, Second paragraph: Please add ", following additional soil delineation,"

between "Site 41" and "will".


8. Removal Action Objective, Page 12, Last paragraph: Please correct the typo "SCLTs" to

"SCTLs".


9. Description of Remedial Alternatives, Page 13, Table 2·5: In the Alternative S41-3 row, under the

Details column, there are two "with clean" in the description. Please remove one.


10. Modifying Criteria, Page 15, Community Acceptance: Complete these dates when they are

known.

Response: The dates (January 10 to February 9, 2011) have been updated in the text.

D-11

11. Rationale for Selected Remedy, Page 16, First paragraph: In the first sentence, please add

"FDEP" between "meet" and "Industrial".


12. Description of Selected Remedy, Page 16, First paragraph: Won't the LUCs restrict the site to

non-residential uses only, along with prohibiting soil excavation or disturbance?

Response: Yes, the last sentence in the first paragraph has been revised as follows:

“…(2) LUCs to restrict site to non-residential activities only and to prohibit soil excavation or disturbance.”

13. Expected Outcomes of Selected Remedy, Page 18, Table 2-7: In the comments column, in the

second paragraph, I believe it should say "by preventing residential use" instead of non-industrial use.

Response: Agreed, the second paragraph in the “Comments” column of Table 2-7 has been revised as follows:

“LUCs will limit exposures via ingestion, dermal contact, and inhalation that result in unacceptable risks under a hypothetical future residential use scenario by preventing residential use and by preventing uncontrolled excavation of soil from the site.”

14. Statutory Determinations, Page 19, First paragraph: Please change "provide" to "provides" in this

sentence.


15. Statutory Determinations, Page 19, Five-Year Review Requirement: At the end of this paragraph

please talk about the yearly LUC reviews that will be conducted as well.

Response: The following sentence has been added as requested:

“In addition, annual LUC compliance inspections will be conducted.”

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D-13